Tag Archives: FBAR Penalities

A common question that many taxpayers have is whether closing a foreign bank account will help with any FBAR obligations or reporting requirements past or present. Even if an account is open for just one day, there is an FBAR filing requirement if the aggregate value of the account or accounts exceeds $10,000. For example, […]

Will my foreign real estate (property) be included in the calculation for the 27.5 OVDP FBAR penalty? One issue that comes up often is how foreign real estate effects how much our clients would owe under the 2012 IRS Offshore Voluntary Disclosure Program (known as the 2012 OVDP or IRS amnesty for offshore bank accounts […]

The IRS launched its first offshore voluntary disclosure program in 2009. Since then, the program has been reintroduced in 2011 and again in 2012 following strong interest. The IRS has collected more $5 billion in back taxes, interest and penalties from over 33,000 taxpayers who have disclosed their offshore accounts under the first two programs. […]

Recently The Fourth Circuit Court of Appeals made a controversial decision regarding willfulness as it applies to FBAR obligations. United States v. Williams, No. 10-2230 (4th Cir. July 20, 2012). This ruling may add risk to opting out of the Offshore Voluntary Disclosure Program or disclosing foreign bank accounts late without entering into the Offshore […]

In a Tax Notes Today report of statements made at the Eastern Pennsylvania Working Together Conference in Malvern, PA, Jason Kuratnick, IRS Associate Area Counsel (Philadelphia), Small Business/Self-Employed Division is reported to have said. The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, […]

Switzerland’s oldest bank was indicted back on February 02, 2012 for conspiring with U.S. taxpayers and others to hide more than $1.2 billion in secret offshore foreign banks and financial accounts and the income they generated from the IRS. It was the first time in history that an overseas bank was indicted by the United […]

Experienced IRS Tax Attorney

Vic was a Senior Trial Attorney with the IRS Office of Chief Counsel in Laguna where he was recognized by the Department of Treasury for his exemplary service. As a Senior IRS Tax Lawyer, Vic has successfully represented clients on all types of tax issues.